City of Sammamish v. Titcomb

CourtWashington Supreme Court
DecidedSeptember 12, 2024
Docket101,894-1
StatusPublished

This text of City of Sammamish v. Titcomb (City of Sammamish v. Titcomb) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Sammamish v. Titcomb, (Wash. 2024).

Opinion

FILE THIS OPINION WAS FILED FOR RECORD AT 8 A.M. ON SEPTEMBER 12, 2024

IN CLERK’S OFFICE SUPREME COURT, STATE OF WASHINGTON SARAH R. PENDLETON SEPTEMBEER 12, 2024 ACTING SUPREME COURT CLERK

IN THE SUPREME COURT OF THE STATE OF WASHINGTON

CITY OF SAMMAMISH, a Washington ) municipal corporation, ) No. 101894-1 ) Respondent, ) ) v. ) En Banc ) JOHN TITCOMB, JR. and LINDE R. ) BEHRINGER, husband and wife, and the ) marital community comprised thereof; ) Filed: Sepetmber 12, 2024 and KING COUNTY, ) ) Petitioners. ) )

JOHNSON, J.—This case asks us to determine the scope of the statutory

condemnation authority granted under RCW 8.12.030,1 and whether a municipality

1 “Every city and town and each unclassified city and town within the state of Washington, is hereby authorized and empowered to condemn land and property, including state, county and school lands and property for streets, avenues, alleys, highways, bridges, approaches, culverts, drains, ditches, public squares, public markets, city and town halls, jails and other public buildings, and for the opening and widening, widening and extending, altering and straightening of any street, avenue, alley or highway, and to damage any land or other property for any such purpose or for the purpose of making changes in the grade of any street, avenue, alley or highway, or for the construction of slopes or retaining walls for cuts and fills upon real property abutting on any street, avenue, alley or highway now ordered to be, or such as shall hereafter be ordered to be opened, extended, altered, straightened or graded, or for the purpose of draining swamps, marshes, City of Sammamish v. Titcomb, No. 101894-1

has authority to condemn private property for stormwater management and fish

passage protection. Here, the city of Sammamish (City) passed Ordinance No.

O2021-526 (Ordinance) authorizing the condemnation of property rights in the

water from George Davis Creek, which runs through petitioners’ property. The

Ordinance listed the purposes for the condemnation as reducing and eliminating

storm drainage conveyance system capacity issues, improving traffic safety,

providing flood protection, and removing barriers to fish passage.

Under RCW 8.12.030, cities have the express authority to take property for

enumerated purposes after paying just compensation. The petitioners do not dispute

this, but they argue that the City had no authority to condemn their property for fish

passage purposes, based on language in the salmon recovery act (SRA), ch. 77.85

RCW, and the holding of Cowlitz County v. Martin, 142 Wn. App. 860, 866-67, 177

P.3d 102 (2008). The Court of Appeals here recognized that the City does have the

authority to condemn private property for stormwater management based on RCW

8.12.030. Review was granted to review the scope of that statutory authority and

whether inclusion of other unlisted purposes for a project taints the grant of

tidelands, tide flats or ponds, or filling the same, within the limits of such city, and to condemn land or property, or to damage the same, either within or without the limits of such city for public parks, drives and boulevards, hospitals, pesthouses, drains and sewers, garbage crematories and destructors and dumping grounds for the destruction, deposit or burial of dead animals, manure, dung, rubbish, and other offal, and for aqueducts, reservoirs, pumping stations and other structures for conveying into and through such city a supply of fresh water, and for the purpose of protecting such supply of fresh water from pollution, and to condemn land and other property and damage the same for such and for any other public use after just compensation having been first made or paid into court for the owner in the manner prescribed by this chapter.”

2 City of Sammamish v. Titcomb, No. 101894-1

authority. City of Sammamish v. Titcomb, 25 Wn. App. 2d 820, 525 P.3d 973,

review granted, 1 Wn.3d 1033 (2023). We affirm the Court of Appeals and hold

that the City is statutorily authorized to condemn property, pursuant to RCW

8.12.030.

FACTS AND PROCEDURAL HISTORY

George Davis Creek is located in the city of Sammamish. The creek runs

through property owned by John Titcomb Jr. and Linde Behringer and out into Lake

Sammamish. In 2018, the City initiated the George Davis Creek Fish Passage

Project (Project). The City listed this as a multipurpose project intended to primarily

remove a number of fish passage barriers in the creek but also to restore streambed

processes and floodplain function in the area.

In 2019, the City applied for and received a grant through the SRA to fund

portions of the Project. The City used the grant to pay for design fees. After

considering a number of design options, the City determined that the best course of

action would be to modify the course of the creek to meet critical requirements of

the Project: capacity to convey a 100-year flood event, conformance to Washington

State fish passage rules, and federal permitting. The City bought the neighboring

property to petitioners in 2020 and decided to reroute the creek across that property

to Lake Sammamish. The City extended an offer to Titcomb and Behringer to

compensate them for the loss of their water rights in the creek. The petitioners

3 City of Sammamish v. Titcomb, No. 101894-1

refused, and negotiations were unsuccessful. The City then initiated condemnation

proceedings.

The City proposed Ordinance No. O2021-526. The Ordinance declared the

public use and necessity for the acquisition of property interests for the Project,

authorizing use of condemnation pursuant to chapter 8.12 RCW. The Ordinance

declared that compensation would be paid to the petitioners, and costs and expenses

would be paid from the City’s stormwater enterprise fund and the general funds of

the City. The Ordinance stated that the relocation of the creek would support

salmon recovery by providing barrier-free fish passage and improved in-stream fish

habitat. The Ordinance also stated that the relocation would “reduce or eliminate

storm drainage conveyance system capacity issues, improve traffic safety of

adjacent roadways by reducing hazardous flooding conditions, and provide greater

flood protection.” Clerk’s Papers at 56.

In 2021, the city council adopted the Ordinance. The City then filed a petition

in superior court to condemn any property rights in the creek that were extinguished

by the Project. The City filed a motion for an order adjudicating public use and

necessity, asserting that the City had authority to condemn the property rights

involved for stormwater facilities, that the Project constituted a public use, and that

the condemnation was necessary to accomplish that use. Petitioners opposed the

condemnation, arguing that the City had no authority to condemn private property

4 City of Sammamish v. Titcomb, No. 101894-1

rights for fish passage purposes, based on language in WAC 420-12-090 and RCW

77.85.050, and in Cowlitz County. The superior court denied the City’s motion and

dismissed the condemnation action.

The City appealed, arguing that it had statutory authority to condemn

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City of Sammamish v. Titcomb, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-sammamish-v-titcomb-wash-2024.